Vital Signs: A wrap-up of revenue cycle management news for November 2023

Welcome to Vital Signs: a monthly roundup of RCM news for independent practices.

The busy holiday season is well underway, and independent medical practices and medical billing companies certainly have a lot to do: Prepare for annual healthcare deductible resets, manage staff vacations, review proposed budgets for 2024, and much more. Equally as important is staying abreast of industry news and developments. Here are 8 revenue cycle management (RCM) stories to put on your radar.   

The specifics: In 2024, physicians will see a 3.4% cut to the Medicare conversion factor, according to the calendar year 2024 Physician Fee Schedule final rule released earlier this month. 

Why it matters: Declining revenue in the face of increased expenses may make it difficult for independent medical practices to remain profitable. 

What’s next: Analyze the impact of this payment reduction on your business. Also, explore potential new revenue opportunities outlined in the 2024 final rule, including caregiver training services, community health integration services, social determinants of health (SDOH) risk assessments, and evaluation and management (E/M) add-on services. 

The specifics: Earlier this month, CMS published its most recent HCPCS Level II quarterly updates. 

Why it matters: This update, which takes effect January 1, 2024, includes considerable changes: 343 new codes and 74 discontinued codes, as well as changes to descriptors, coverage, and payment for existing codes. 

What’s next: Familiarize yourself with new codes, deletions, and changes. Research CPT® Assistant for guidance on the new procedures. Also, review your charge description master (CDM). Do the new codes impact any supplies or implants? Do you need to inactivate certain line items? Update payment or descriptions?

The specifics: If you think you might qualify for an MIPS hardship exception, now is the time to explore 2 available options. Applications are due January 2, 2024. 

Why it matters: If you’ve faced extreme and uncontrollable circumstances such as a disaster, practice closure, severe financial distress, or vendor issues, an MIPS exception could give you a reprieve. 

What’s next: Familiarize yourself with the reasons CMS would grant a hardship exception. If you think you might qualify, submit an application. Then keep your fingers crossed.

The specifics: The OIG recently released updated compliance program guidance that helps medical practices advance their compliance efforts. 

Why it matters: This is the first update of the OIG’s compliance program guidance in 15 years.

What’s next: Review the section on the 7 elements of a compliance program infrastructure as well as the OIG’s suggestions on how to tailor these elements to individual and small-group physician practices. 

The specifics: CMS recently published a playbook that outlines an initial framework for federal agencies to improve the social circumstances of individuals and communities. 

Why it matters: The playbook has the potential to accelerate innovation and practical solutions to improve social circumstances and achieve better health outcomes. 

What’s next: Be sure to review the extensive appendices in the playbook that highlight federal programs, toolkits, and guidance to help medical practices and others improve the delivery of health and social services.

The specifics: According to a recent MGMA survey, 89% of medical practices say prior authorizations are very or extremely burdensome. Other top regulatory burdens include audits and appeals, MIPS/APMs, surprise billing and good faith estimates, and Medicare Advantage chart audits.

Why it matters: The increased burden year over year allows MGMA to educate Congress and the Administration about obstacles to delivering high-quality patient care.

What’s next: Identify the biggest regulatory burdens for your medical practice or medical billing company. Take the time to brainstorm solutions and network with others to identify best practices. 

The specifics: The Texas OIG recently identified these common telemedicine billing errors: Billing for multiple telemedicine or telehealth services on the same client in a short period of time, impossible hours, billing an E/M service when the physician determines an in-person or video telemedicine visit is required within 24 hours or the next available appointment time, and inappropriately billing for excess time.

Why it matters: These errors could be flying under the radar at your medical practice as well. 

What’s next: Look for patterns and trends within your own billing. Audit your claims and invest in provider and staff education to improve compliance and revenue integrity.

The specifics: Following its theme of providing physicians with actionable resources, the American Medical Association (AMA) once again published an article reminding medical practices to review needs and business relationships for the New Year. Equally important is to plan ahead for possible cash flow delays to ensure the financial stability of the practice at the beginning of the year when most patients are meeting insurance deductibles and out-of-pocket responsibilities.

Why it matters: For many practices, it may be a tough year ahead, thanks to payment cuts, rising costs, and ongoing healthcare staffing shortages. Proactive planning will be paramount.

What’s next: The AMA says to take these steps in the last few weeks of 2023 and heading into 2024: Work with practice administrators to ensure patients seeking high-cost treatments, procedures, and surgeries can be seen before the end of the year; plan ahead for staffing shortages; know how many supplies to order to avoid supply shortages; review payer relationships and revenue cycles; and enroll in payer platforms to take advantages of electronic submission of prior authorizations.